GDPR – Large scale processing

The GDPR refers to large scale processing several times. Questions about what is meant by this come up on a regular basis. We have produced a short video with details on factors to consider, examples of large scale processing and examples of what isn’t large scale processing. Get in touch if you need help with… Read More

Are you meeting the GDPR Accountability principle?

Meeting the General Data Protection Regulation (GDPR) requirements isn’t a one-off ‘set and forget’ activity. Ongoing work is needed to ensure the requirements continue to met, this is covered by the Accountability principle in Article 5. It states that the controller “shall be responsible for, and be able to demonstrate compliance with, paragraph 1”; and… Read More

CNIL – causes of reported data breaches (May – October 2018)

The CNIL (the French Data Protection Authority) received 742 notifications of personal data breaches (and see the original report in French) that affected over 33 million individuals located in France or elsewhere. 695 related to confidentiality breaches. The accommodation and food services sector had the highest number of breaches – 185. This is due to a specific case… Read More

#GDPR – number of complaints in the first month

IAPP has published details about the number of complaints received by different data protection authorities (DPAs) in the first month after the GDPR started to be enforced. It isn’t a full picture as there are no details from Croatia, Cyprus, Finland, Germany, Greece, Hungary, Italy, Latvia, Lithuania, Luxembourg, Poland, Portugal and Spain. The accuracy and consistency of… Read More

How to track down your personal data (Data Mapping)

One of the early stages to prepare for the General Data Protection Regulation (GDPR) is identifying the Personal Data you process; this blog provides a framework to build a Personal Data Inventory. An inventory is not a requirement of the GDPR, but it is a good way to build up a picture of the personal… Read More

Legitimate Interests – 3 part test

Legitimate interests (LI) is one of the lawful basis for processing personal data. The ICO say it is appropriate “where you use people’s data in ways they would reasonably expect and which have a minimal privacy impact, or where there is a compelling justification for the processing”. The three parts to the test to identify a LI have been… Read More

Accountability and Governance – Documentation #GDPR #DPB

Details of documentation requirements for Accountability and Governance under the GDPR and Data Protection Bill are on the ICO website. A mind map has been created to act as a quick reference. Click on the image to view the full-size mind map. You can use the Checklist on the ICO website page to track what… Read More

My top 3 items from the Information Commissioner’s fireside chat

On Tuesday 17 October I was at IAPP’s ‘fireside chat’ with Elizabeth Denham, the Information Commissioner. The top 3 items for me were: GDPR certification – details to be published in early 2018, the ICO is leading the work on this in WP29. The Commissioner thought it should be based on Accountability and mentioned the approach… Read More

The impact of the GDPR on sending emails and networking

On 25 May 2018 the General Data Protection Regulation (GDPR) replaces the Data Protection Act (DPA). The aim is to give individuals more control over how their personal data is used and get businesses to be more transparent over how it will be used. The UK Government have confirmed that Brexit has no impact. Businesses… Read More

Wetherspoons stop monthly newsletters – GDPR related?

This morning I received an email from Wetherspoons – I am a customer and did sign up to receive updates – saying they will no longer be sending emails as many consider this intrusive. I agree that some people can find this intrusive, but at the same time think this could be part of their General… Read More